Swamy, who filed the complaint in the Special Central Bureau of Investigation Court, also named "unknown" or unidentified CBI officials for protecting Tata in the 2G spectrum case.

Special Judge O.P. Saini fixed January 11 for consideration of the complaint and argument.

The complaint filed by Swamy`s counsel Tarun Goomber has named two then directors of Tata Realty and Infrastructure Limited (TRIL) F.N. Subedar and P.D. Karkaria, then Chief Financial Officer Kishore Selatore, then Company Secretary M.V. Balaji, Unitech`s Chairman Ramesh Chandra, Managing Director Sanjay Chandra and Ajay Chandra and company official S. Ravi Aiyer.

"All these crimes and illegalities were committed at the behest of accused Ratan Tata as he and his companies were barred from obtaining the licences as per the Clause Numbers 5.1 and 8 of the guidelines of the Unified Access Service License (UASL), 2005, legally," the complaint said.

Swamy alleged that various Tata Group companies were used to route the money to the various companies of Unitech Group and finally managed to a launder a sum of Rs 1,700 crore for their illegal purpose during the period of March 2007 to March 2008.

Swamy said that the movement was facilitated by eight companies of Unitech Wireless. After receiving the fund, the companies` names were changed to conceal the identity.

Earlier, the cut-off date for receiving application for spectrum licence was October 10, 2007, but Raja suddenly changed the cut-off dates to September 25, 2007.

As per Raja`s first-come-first-serve policy, the letter of intent would be issued to those companies who depositted their fees first.

It helped real estate company Unitech in getting telecom licence even though the company was a new entrant in the telecommunication sector.

Of the Rs 1,700 crore funds received from Tata Reality, Unitech spent Rs 1,651 crore on obtaining the licence.

He stated that during her questioning, Radia disclosed the conspiracy and money laundering offence committed by Tata but the probe agency failed to nail the accused person.

Swamy submitted various documents, including from the Ministry of Corporate Affairs`s serious fraud investigation office (SFIO).

He has requested court to initiate proceedings against the accused under various charges dealing with cheating, fraud, forgery, criminal conspiracy and under the provisions of the Prevention of Money Laundering Act.

Swamy has also requested court to direct the Enforcement Directorate (ED) to conduct further investigation to unearth the deep-rooted conspiracy.